What Project 2025 Would Do to the Environment – and How We Will Respond

The policy playbook known as Project 2025 is 900 pages, and 150 of them are about how to destroy the environment. This deregulatory agenda written by former government officials and Heritage Foundation staff would strip away our rights to clean air, clean water, and a healthy planet. It would trade these basic freedoms to help polluters profit.

Though the scope of planning written down in Project 2025 is new, many of the ideas it presents are not. At Earthjustice, we’ve seen presidential administrations push similar agendas before — and through the courts we have pushed back.

Yet we know that the lives lost and habitats obliterated under such disastrous policies cannot be restored, even if the policies themselves are reversed. We are also alarmed by proposed tactics we have not seen any previous administration attempt, particularly the ways in which Project 2025 undermines government staff charged with overseeing health and environmental protections.

We are prepared to defend the environment and communities no matter who holds political office. Here are some of the Project 2025 recommendations we’re most concerned about:

Grizzly bear near Roaring Mountain in Yellowstone National Park. (A. Falgoust / NPS)

Taking a hatchet to bedrock environmental laws

What Project 2025 says:

• Gut the Endangered Species Act (ESA): Project 2025 would rewrite the most successful legal tool we have for protecting wildlife in ways that would harm imperiled species. It specifically calls for removing protections from gray wolves and Yellowstone grizzlies.
• No need for national monuments: Another proposal would repeal the Antiquities Act, which would strip the president of the ability to protect priceless public lands and waters as national monuments.
• Weaken the Clean Air Act: Project 2025 would nix the part of the law that requires the Environmental Protection Agency (EPA) to set health-based air quality standards.
• Less say for communities in environmental decisions: The plan would undermine key portions of the National Environmental Policy Act (NEPA), which ensures you have a voice in major projects built near you.

Why we’re prepared:

• Defending endangered species: The Trump administration went after both Yellowstone grizzlies and the Endangered Species Act itself. Both times, Earthjustice went straight to court. One of our cases spared the grizzlies from planned trophy hunts, and and the Biden administration subsequently reversed some damaging changes to the ESA.
• Defending national monuments: When the Trump administration gutted Bears Ears and Grand Staircase-Escalante National Monuments in Utah, Earthjustice immediately sued. Protections for the monuments have now been restored. We also helped defend the monuments from a later legal challenge by the state of Utah that attacked the Antiquities Act itself.
• Defending NEPA: This summer, when 21 state attorneys-general sued to block important updates to NEPA, we intervened to fight back. The updates will ensure that critical infrastructure needed for the clean energy transition is built quickly and equitably and is resilient to climate change.

Fossil fuel drilling sites in Alaska’s Western Arctic, in an around the Lake Teshekpuk area. (Kiliii Yuyan for Earthjustice)

More mining and fossil fuel development on public lands

What Project 2025 says:

• Prioritize oil and gas: Project 2025 tells the agencies that manage federal lands and waters to maximize corporate oil and gas extraction. It calls for approving more pipelines like Keystone XL and Dakota Access.
• Willow? Make it bigger: The agenda explicitly aims to expand the Willow Project, which is already the largest proposed oil and gas undertaking on U.S. public lands.
• Target iconic landscapes: The project also calls for drilling in Alaska’s Arctic National Wildlife Refuge and mining in Minnesota’s Boundary Waters wilderness, among other irreplaceable natural treasures.

Why we’re prepared:

• Fighting on all fronts: Under the Trump administration, Earthjustice challenged an aggressive extractive agenda at every turn. Our victories included winning protections for 128 million acres of ocean and hundreds of thousands of acres of sage-grouse habitat threatened by oil and gas development.
• We’ve defended many of the places Project 2025 targets:
  • We have been defending the Arctic National Wildlife Refuge from fossil fuel development since the 1980s, and we celebrated last year when the government canceled a set of illegal oil leases
  • Our litigation and advocacy has helped secure a 20-year mining ban in the Boundary Waters.
  • Currently, we are fighting the Willow Project in court.

A water researcher tests a sample of water for PFAS at the U.S. Environmental Protection Agency Center For Environmental Solutions and Emergency Response in Cincinnati. (Joshua A. Bickel / AP)

Undermining science and the regulation of toxic chemicals

What Project 2025 says:

• Trust the chemical companies: Project 2025 tells the EPA to be more open to industry science and to stop funding major research into toxic chemical exposure.
• Make it harder to regulate chemicals: The plan calls for the EPA to meet an absurdly high standard of proof that a chemical is hazardous before deciding to regulate it. This would give chemical companies greater freedom to put toxic substances into our air, water, and products.
• Forever chemicals are fine: Project 2025 would walk back the determination that PFAS — the “forever chemicals” linked to reproductive harms, developmental delays, and increased risk of cancer — are a hazardous substance.

Why we’re prepared:

• Fighting for the full use of the law: The government has the authority to protect us from harmful chemicals under a critical law called the Toxic Substances Control Act, or TSCA. Earthjustice is fighting to force the Biden administration to use this law more effectively.
• Pushing for transparency: When the Trump administration EPA understated the risks of deadly chemicals, Earthjustice sued under TSCA.
• Taking on PFAS: Earthjustice has fought for an array of protections against PFAS. We have helped protect communities from PFAS incineration, defended the public’s right to know about PFAS releases, pushed for stronger state laws regulating PFAS in water, and more.

The Park Fire burns through the night on July 30, 2024 near Chico, California. (David McNew / Getty Images)

Ending government efforts to address the climate crisis

What Project 2025 says:

• The plan’s authors are climate skeptics: The document refers pointedly to “the perceived threat of climate change.”
• Climate solutions? Don’t need ‘em: Project 2025 calls for undoing many of the clean energy investments in the Inflation Reduction Act, the largest climate solutions bill in history. It also supports Congressional efforts to repeal the law entirely.
• Shut down climate research: The plan would get rid of more than a dozen government offices and agencies that study climate change.

Why we’re prepared:

• Confronting government with climate reality: We have fought every administration in recent decades to include climate change impacts in various decisions. Earlier this century, we joined in a suit that became a landmark Supreme Court ruling, Massachusetts v. EPA, which found that carbon emissions are air pollutants and consequently the EPA must set limits on such pollution. We will defend the necessity to combat climate change — but further delays will hurt us all. An analysis from Energy Innovation found that enacting Project 2025 would increase carbon emissions by 2.7 billion tons by 2030 — equivalent to the annual emissions of India. These policies would cost households $32 billion in higher energy costs, result in 1.7 million lost jobs, and decrease the U.S. GDP $320 billion per year by 2030.
• Fighting for science: Earthjustice has previously defended the critical role of scientific experts within the government. In 2020, we won a lawsuit challenging the Trump administration’s illegal decision to remove independent science advisors from the EPA.

Catherine Flowers, the founding director of the Center for Rural Enterprise and Environmental Justice, talks about open-sewage issues in Hayneville, Alabama, alongside homeowner Charlie Mae during a tour of Lowndes County in 2022. (Lance Cheung / USDA)

Eliminating environmental justice programs

What Project 2025 says:

• Environmental justice is not the government’s problem: Project 2025 questions whether the government should address the ways that communities of color and low-income communities are disproportionately exposed to dangerous pollution.
• Get rid of staff who work on these issues: The plan calls for disbanding offices with the Department of Justice and the EPA that focus on environmental justice.

Why we’re prepared:

• An environmental justice first: In 2021, after years of pushing by Earthjustice and our partners, the Justice Department opened its first-ever environmental justice investigation, looking into whether an Alabama county was managing sewage in a way that disproportionately harmed Black communities.
• Raising our voice: We helped advocate for billions of dollars of funding from the Inflation Reduction Act to go to the communities that need it most.